Revised Georgia EPD Construction Permits

Georgia EPD has reissued general permits for stormwater discharge from construction sites. As background, NPDES General Permit No. GAR100000 for storm water discharges associated with construction activity was issued in 2000 and regulated construction activities that disturbed five (5) or more acres. In 2003, the permit was reissued as three general permits that regulate construction activities that disturb one (1) or more acres: NPDES Permit No. GAR100001 - regulates stand-alone construction sites, NPDES Permit No. GAR100002 - regulates infrastructure construction sites, and NPDES Permit No. GAR100003 - regulates common development construction sites.

 
 SWPPP and SWPPP Training For
Residential Site Construction

Summary of Changes to Permit

• The term “projects” has been changed to “sites” for consistency with the permit definitions.
• The draft permits contain changes as a result of EPD’s implementation of the NPDES Electronic Reporting Rule. Beginning on the effective date of the permit, All Notices of Intent (NOI), Modifications and Notices of Terminations (NOT) must be submitted through EPD’s electronic submittal portal. EPD is preparing an electronic method for submitting sampling reports. ES&PC Plans required to be submitted to the EPD District Offices must now be submitted electronically through EPD’s electronic submittal portal or as a PDF on CD-ROM or other storage device.
• All references to anionic polyacrylamide (PAM) have been replaced by “flocculants or coagulants”, and “matting or blankets” has been replaced with “slope stabilization” to be consistent with the most recent Manual for Erosion and Sediment Control.
• BMP options which were no longer “over and beyond” have been removed from the options to address impaired waters.
• The permit now requires a large sign (minimum 4 feet x 8 feet) must be posted on site by the actual start date of construction. The sign must be visible from a public roadway. The sign must identify : (1) the construction site, (2) the permittee(s), (3) the contact person(s) along with their telephone number(s), and (4) the permittee-hosted website where the ES&PC Plan can be viewed. The sign must remain on site and the ES&PC Plan must be available on the provided website until a NOT has been submitted.
• EPD has added a BMP option to address impaired waters, to conduct inspections during the intermediate grading and drainage BMP phase and during the final BMP phase of the project by a certified Level II design professional to improve overall site management quality control, and to install Post Construction BMPs which remove 80% TSS
• EPD has clarified that Whenever a permittee finds that a BMP has failed or is deficient (beyond routine maintenance) and has resulted in sediment deposition into waters of the State, the permittee shall submit a summary of the violations to EPD correct such BMP as follows: 
• When the repair does not require a new or replacement BMP or significant repair, the BMP failure or deficiency must be repaired by the close of the next business day from the time of discovery; 
• When the repair requires a new or replacement BMP or significant repair, the installation of the new or modified BMP must be completed and the BMP must be operational by no later than seven (7) days from the time of discovery. If it is infeasible to complete the installation or repair within seven (7) days, the permittee must document why it is infeasible to complete the installation or repair within the seven (7) day timeframe and document the schedule for installing or repairing the BMPs and making the BMPs operational as soon as feasible after the seven (7) day timeframe.

Summary of Changes to Erosion, Sedimentation and Pollution Control Plans

Revisions to the requirements for Erosion, Sedimentation and Pollution Control Plans include:

• For building materials, building products, construction wastes, trash, landscape materials, fertilizers, pesticides, herbicides, detergents, sanitary waste and other materials present on the site, provide cover (e.g. plastic sheeting, temporary roofs) to minimize the exposure of these products to precipitation and to stormwater, or a similarly effective means designed to minimize the discharge of pollutants from these areas. Minimization of exposure is not required in cases where exposure to precipitation and to stormwater will not result in a discharge of pollutants, or where exposure of a specific material or product poses little risk to stormwater contamination (such as final products and materials intended for outdoor use).
• The permit requires permittees to measure and record rainfall within disturbed areas of the site that have not met final stabilization once every 24 hours except any non-working Saturday, non-working Sunday and non-working Federal holiday.

Construction Activities Not Requiring Permit Coverage

EDP has also clarified that permit coverage is not required for discharge of storm water associated with infrastructure road construction sites that consist solely of the installation of cable barriers and guard rail for an existing facility within the existing rights-of-way. The construction activity shall, as a minimum, implement and maintain best management practices, including sound conservation and engineering practices to prevent and minimize erosion and resultant sedimentation, which are consistent with, and no less stringent than, those in the “Manual for Erosion and Sediment Control in Georgia”. In order to be eligible for this exemption the project must comply with the following conditions: (1) no mass grading shall occur on the project, (2) the project shall be stabilized by the end of each day with temporary or permanent stabilization measures, (3) final stabilization must be implemented at the end of the project.

 Permit coverage is also not required for discharge of storm water associated with infrastructure construction sites that consist of the installation of buried utility lines and comply with the following conditions: (1) solely installed via vibratory plow, (2) the conduit does not exceed 4 inches in diameter, and (3) occurs within an existing stabilized right-of-way. The construction activity shall, as a minimum, implement and maintain best management practices, and the following conditions: (1) no mass grading shall occur on the project, (2) no tree clearing, (3) no change in grade, (4) the project shall be stabilized by the end of each day with temporary or permanent stabilization measures, and (5) final stabilization must be implemented at the end of the project.

    

 Caltha LLP | Your Stormwater Permit, SWPPP and Spill Plan Partner

Stormwater Discharge From Recycling Facility To Georgia Impaired Stream

Caltha LLP Project Summary

Project: Industrial Storm Water Permitting, SWPPP Certification & Compliance with Impaired Waters Requirements
Client: Scrap Metal Recycling facility
Location(s): Georgia

Key Elements: SWPPP preparation, Stormwater monitoring, Compliance plan, Impaired waters consulting

Overview: Caltha LLP has provided consulting services to this scrap metal recycling facility to meet the Georgia industrial storm water rules and the Georgia Environmental Protection Division of the Department of Natural Resources general industrial discharge permit. Services included preparing facility stormwater pollution prevention plan using Caltha’s Georgia SWPPP template, preparation of site-specific inspection checklists to comply with State inspection requirements, preparation of site-specific stormwater monitoring plan to meet State requirements applicable to this industrial sector, including additional requirements for discharges to listed impaired waters. Caltha then provided ad hoc technical support to facilities to address questions during roll-out of the compliance programs.

 Example Of Industrial Waste Being Discharged 

To Storm Sewer

For more information on Caltha LLP SWPPP services, go to the Environmental Health & Safety Plan | Spill Plan Information Request Form.

Click here to review other example Caltha industrial stormwater projects. Click here to review other Caltha projects in Georgia and GA regulatory updates.

Warehousing and Logistics Facilities Needed Storm Water Permit And SWPPP

Caltha LLP Project Summary

Project: Industrial Storm Water Permitting & Compliance
Client: International Retailer
Location(s): California, Washington, Utah, Georgia, Florida, Virginia, North Carolina, Pennsylvania, Ohio, Massachusetts, New York, Kansas, Virginia, Louisiana, Texas, Tennessee, Minnesota, Illinois, Indiana, South Carolina, Colorado, Nevada, New Jersey, Connecticut, Missouri

Key Elements: SWPPP preparation, Stormwater monitoring, Compliance plan, Permit application

Overview: Caltha LLP has provided consulting services to this international retailer at multiple logistics and warehousing locations to comply with individual State industrial stormwater rules. Services included preparing facility stormwater pollution prevention plans, preparation of State or EPA application forms (Notice of Intent), preparation of site-specific inspection checklists to comply with individual State inspection requirements, preparation of site-specific stormwater monitoring and benchmark monitoring plans to meet State requirements applicable to this industrial sector. Caltha then provided ad hoc technical support to facilities to address questions during roll-out of the compliance programs.

Leaking Hydraulic System On Trash Compactor 

Contaminates Stormwater Discharge

For more information on Caltha LLP SWPPP services, go to the Environmental Health & Safety Plan | Spill Plan Information Request Form.

2017 Georgia General Pemit | What If I Exceeded Benchmarks Under Current Permit?

The current Georgia industrial stormwater general discharge permit expires on May 30, 2017. The revised NPDES General Storm Water Permit For Discharges of Stormwater Associated With Industrial Activity (2017 IGP) was finalized in 2016 and becomes effective on June 1, 2017. The revised permit made some modifications to requirements permitted facilities must meet, but not as substantial of changes as compared to the release of the 2012 IGP.

If a facility exceeded the impaired waters benchmark based on the criteria presented in 2012 IGP permit, then the facility has the option to conduct 12 months of flow-weighted composite sampling to demonstrate the discharge does not cause or contribute to an exceedance of water quality standards, or make the necessary improvements to the facility to achieve the instream water quality standard as an effluent limit within 36 months. If the facility still is unable to meet the impaired waters benchmark(s), they may not be authorized to discharge stormwater under this permit and may be required to apply for an individual NPDES permit or alternative general permit. Facilities that failed to meet the applicable benchmarks of the 2012 IGP permit have the option to sample their discharge(s) for 12 months to confirm whether the facility causes or contributes to an exceedance of the applicable Water Quality Standard, or prevent all exposure of industrial processes, materials, and equipment to stormwater, and/or capture and treat storm events of up to 1.2 inches within industrial areas exposed to stormwater within 36 months.

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training. For further information contact Caltha LLP at
info@calthacompany.com or Caltha LLP Website

Georgia 2017 IGP | What If My Facility Is Already Covered Under the Existing Permit?

The current Georgia industrial stormwater general discharge permit expires on May 30, 2017. A revised permit NPDES General Storm Water Permit For Discharges of Stormwater Associated With Industrial Activity (2017 IGP) was finalized in 2016 and becomes effective on June 1, 2017. The revised permit made some modifications to requirements permitted facilities must meet, but not as substantial of changes compared to the release of the 2012 IGP.


Current permittees are required to submit a new Notice of Intent (NOI) to obtain coverage under the 2017 IGP and to maintain coverage for discharging stormwater associated with industrial activities. Facilities previously covered under the 2012 IGP will have up to 30 days to submit the new NOI for coverage under the updated 2017 IGP after the effective date.

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training. For further information contact Caltha LLP at
info@calthacompany.com or Caltha LLP Website

Georgia Industrial Stormwater SWPPP Template and Compliance Plan

The Georgia Environmental Protection Division(EPD) has finalized a revised General Permit for Storm Water Discharges Associated with Industrial Activity (Multi-Sector General Permit, or MSGP). This permit replaces the previous Georgia general permit, which had expired in July 2011. The Georgia general permit is modeled after the US EPA MSGP and defines sector specific requirements for each of 29 different industrial sectors. For many facilities subject to the previous general permit, the revised MSGP will require a significant revision to the facility stormwater pollution prevention plan, or SWPPP. Facilities must submit a new NOI for permit coverage by June 30, 2012, including certification that the operation is in compliance with new requirements.

Read a Summary of the Revised Georgia Industrial Permit Requirements
To reduce the level of effort required for facilities to come into compliance with new permit requirements, Caltha LLP has prepared a SWPPP template based on Georgia permit requirements, including Georgia specific quarterly inspection checklist, quarterly visual assessment checklist, quarterly benchmark monitoring checklist, and an annual comprehensive site inspection checklist. Caltha has also prepared a Georgia Stormwater Permit Compliance Plan to assist permitted facilities in organizing and planning new compliance requirements under the EPD general permit.

For more information on Caltha LLP SWPPP services, go to the Environmental Health & Safety Plan | Spill Plan Information Request Form.

Summary of Final Georgia Industrial General Permit

On April 16, the Georgia Environmental Protection Division (EPD) released its final industrial stormwater general permit for industrial facilities. These permits cover stormwater discharges from certain types of industrial and “industrial-like” operations that are required to have a NPDES permit to discharge stormwater. The previous general permit expired in 2011. The revised permit includes some of the same requirements that were included in the 2006 IGP industrial stormwater permit. However, some significant changes have also been included, especially relating to stormwater monitoring requirements.


You can review a Regulatory Briefing on the final permit using the following link:

Summary of Revised Georgia Industrial Stormwater Discharge Permit


The final permit is effective June 1, 2012; all facilities covered under the previous permit must submit a new NOI by June 30, 2012, including certification that the facility is in compliance with the requirements of the new permit.

Caltha LLP provides expert consulting services to public and private sector clients in Georgia and nationwide to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training.

For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website

New Benchmark Monitoring Requirements For Discharges To Impaired Waters

The 2012 NPDES General Permit No. GAR050000 for Storm Water Discharges Associated with Industrial Activity (2012 IGP) was issued as a third draft for public comment on January 17, 2012. Comments are being accepted from January 17 to March 16, 2012. Georgia Department of Natural Resources - Environmental Protection Division (EPD) anticipates the final industrial permit will be issued in April 2012.

Review a Regulatory Briefing on the Georgia 2012 IGP

The 2012 IGP has certain requirements that apply only to facilities that discharge either directly to an impaired water, or to a tributary to an impaired water, if the facility is located less than one mile from the impaired water. An impaired water is a water body, or part of a water body, that does not meet State Water Quality Standards and has been placed on the 303(d) Impaired Waters list submitted to and approved by US EPA.

If the pollutant of concern (POC), such as sediment, could be exposed and/or could be contained in the stormwater run-off, facilities are required to conduct benchmark monitoring twice each quarter, rather than once per year. In addition, the applicable benchmark concentration becomes equal to the State Water Quality Standard, and not the sector-specific benchmarks in the 2012 IGP (which are generally higher). If benchmarks are not exceeded, sampling could be reduced to twice per year.

For those facilities that conducted impaired waters monitoring under the previous permit (2006 IGP) and passed all benchmarks, the additional monitoring under the 2012 IGP is twice per year.

Some facilities may be able to certify that the POC is not present at the facility, in which case they are not required to conduct the additional impaired water monitoring. Finally, some facilities may be able to conduct studies or analyses that demonstrate that their stormwater discharge will meet applicable Water Quality Standards. In this case, the analysis must be certified by a Professional Engineer or Professional Geologist and approved by EPD.

Caltha LLP provides expert consulting services to public and private sector clients in Georgia and nationwide to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training.

For further information contact Caltha LLP at

info@calthacompany.com or Caltha LLP Website

No Exposure Exclusion NEE Requirements Under Revised EPD Industrial Permit

The 2012 NPDES General Permit No. GAR050000 for Storm Water Discharges Associated with Industrial Activity (2012 IGP) was issued as a third draft for public comment on January 17, 2012. Comments are being accepted from January 17 to March 16, 2012. Georgia Department of Natural Resources - Environmental Protection Division (EPD) anticipates the final industrial permit will be issued in April 2012.

Click here to review a Regulatory Briefing on the 2012 ICP

One of the significant requirements in the final draft permit is related to facilities that submit a No Exposure Exclusion (NEE). Those facilities that have certified to a condition of No Exposure by submitting the Industrial No Exposure Exclusion Certification form are exempt from the IGP as long as the condition of No Exposure is maintained. However, Georgia is unique is requiring that NEE facilities document compliance with the NEE requirements. Owners and operators of facilities for which an NEE form is submitted are required to conduct quarterly inspections each year to ensure that a condition of No Exposure is maintained at the facility. Results of the inspections must be maintained at the facility and available to EPD upon request.

If an inspection shows that any condition of the No Exposure Exclusion does not exist, then appropriate remedial measures are required within 30 days of the inspection, or the facility owner or operator must submit an NOI to obtain coverage under the general permit

The NEE form must be submitted on every permit cycle re-issuance. Therefore facilities that submitted their NEE form under the previous permit must resubmit their certification within 30 days after the effective date of the 2012 IGP.

Caltha LLP provides expert consulting services to public and private sector clients in Georgia and nationwide to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training.

For further information contact Caltha LLP at

info@calthacompany.com or Caltha LLP Website

Georgia 2012 Industrial General Permit Update

The 2012 NPDES General Permit No. GAR050000 for Storm Water Discharges Associated with Industrial Activity (2012 IGP) was issued as a third draft for public comment on January 17, 2012. Comments are being accepted from January 17 to March 16, 2012. Georgia Department of Natural Resources - Environmental Protection Division (EPD) anticipates the final industrial permit will be issued in April 2012. The draft revised permit, which included significant changes from the expired general permit. Earlier drafts were issued in June and August 2011.

[Read summary of earlier IGP version]
[Read a Regulatory Briefing summarizing key elements of the 2012 ICP]

Once finalized, current permittees covered under the 2006 IGP will be required to submit a new Notice of Intent (NOI) within 30 days after the effective date of the new permit. New dischargers commencing discharge after the effective date of the 2012 IGP must submit an NOI for coverage 7 days prior to commencing discharge. Also, existing facilities which had previously filed for a “No Exposure Exclusion‟ (NEE) must submit a new NEE form no later than 30 days after the effective date of the 2012 IGP. The 2012 IGP requires facilities that claim they have no storm water discharges associated with industrial activity file a “No Discharge Exclusion” (NDE) form which must be certified by a professional engineer.

Caltha LLP provides expert consulting services to public and private sector clients in Georgia and nationwide to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training.

For further information contact Caltha LLP at

info@calthacompany.com or Caltha LLP Website

MS4 Storm Water Discharge Permit Issues To Georgia DOT

The Georgia Environmental Protection Division (EPD) issued National Pollutant Discharge Elimination System (NPDES) Permit No. GAR041000 to the Georgia Department of Transportation (GDOT) for storm water discharges from its municipal separate storm sewer system (MS4) to waters of the State.

This first-time permit requires GDOT to reduce pollutants in storm water through six minimum control measures:

1. Public Education and Outreach,


2. Public Involvement/Participation,


3. Illicit Discharge Detection and Elimination,


4. Construction Site Storm Water Control,


5. Post-Construction Storm Water Management, and


6. Pollution Prevention/Good Housekeeping.
   

The permit covers GDOT roadway drainage, bridges, detention ponds, etc. in 145 urban areas around the State.

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training.

For further information contact Caltha LLP atinfo@calthacompany.comorCaltha LLP Website